NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
|---|---|
ID: aiam2554OpenMr. Michael Shillinger, AM General Corporation, 32500 Van Born Road, Wayne, MI 48148; Mr. Michael Shillinger AM General Corporation 32500 Van Born Road Wayne MI 48148; Dear Mr. Shillinger: This responds to your oral request of March 28, 1977, for clarificatio of the language of S5.4.1 of Standard No. 217, *Bus Window Retention and Release*. In particular, you ask whether the long side of a rectangular roof exit is required to be parallel to the center line of a bus.; S5.4.1 requires that an exit provide an opening large enough to admi unobstructed passage, keeping a major axis horizontal at all times, of an ellipsoid generated by rotating about its minor axis an ellipse having a major axis of 20 inches and a minor axis of 13 inches.' Further, S5.2.1 of the standard states that a roof exit shall meet these requirements when the bus is overturned on either side. The requirement that the major axis be kept horizontal while the bus is on its side means that the major axis, and therefore the long side of the rectangular roof exit, would be parallel to the center line or the side wall of a bus.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam3187OpenSheila McDevitt, Esq., 7976 Seminole Boulevard, Suite 6, Seminole, FL 33542; Sheila McDevitt Esq. 7976 Seminole Boulevard Suite 6 Seminole FL 33542; Dear Mr. McDevitt: This is in response to your question to Mr. Schwartz of my offic concerning the need to prepare an odometer statement for a vehicle which is declared a total loss by an insurance company.; No odometer disclosure statement is required for a vehicle that is total loss. The National Highway Traffic Safety Administration (NHTSA) has determined that when there is no possibility that the vehicle can be put back on the road then it ceases to be a motor vehicle for purposes of the Federal odometer disclosure requirements.; If a vehicle is badly damaged, but will be rebuilt, an odomete disclosure statement must be issued. An insurance compnay that sells to a salvage dealer a vehicle that can be put back on the road must issue a disclosure statement to that dealer. The salvage dealer who rebuilds the vehicle must then issue a disclosure statement to the party who purchases the rebuilt vehicle. Likewise, if a salvage dealer sells the vehicle to someone else who is going to rebuild the vehicle, the salvage dealer must issue a disclosure statement to that person. Each time the ownership of that vehicle is transferred, the transfer must be accompanied by an odometer disclosure statement prepared by the owner and presented to the buyer. This requirement does not end until the owner makes a good faith determination that the vehicle cannot be put back on the road. The owner should make that determination and not rely on the buyer's representations as to how the vehicle will be used.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam0888OpenMr. Elmar Hansen, Hansen and Associates, 1403 Timber Drive, Elgin, illinois 60120; Mr. Elmar Hansen Hansen and Associates 1403 Timber Drive Elgin illinois 60120; Dear Mr. Hansen: This is in response to your telephone inquiry of August 15, 1972 regarding Standard 125, Warning Devices. You asked whether the standard permits the production of a warning device the triangular portion of which would not be collapsible. Standard 125 does allow this configuration.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2750OpenM. Kashu, Assistant Director, Asahi Glass Company, Ltd., 1-2 Marunouchi, 2-Chome, Chiyoda-Ku, Tokyo, 100, Japan; M. Kashu Assistant Director Asahi Glass Company Ltd. 1-2 Marunouchi 2-Chome Chiyoda-Ku Tokyo 100 Japan; Dear Mr. Kashu: This is in reply to your inquiry of January 23, 1973. Speedometer covers on motorcycles are not subject to FMVSS No. 205. Sincerely, Francis Armstrong, Acting Director, Office of Vehicle Safet Compliance Enforcement; |
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ID: aiam2044OpenMr. Kenneth J. Mason, 1314 Spruce Street, Wausau, WI 54401; Mr. Kenneth J. Mason 1314 Spruce Street Wausau WI 54401; Dear Mr. Mason: We have received your letter of August 7, 1975, concerning the Unifor Tire Quality Grading Standards established by this agency. Although the formal comment period for the proposals on which this regulation is based ended April 23, 1975, we appreciate your support for the regulation as issued. A copy of your letter has been placed in our public files.; Thank you for expressing your interest. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2042OpenMr. Kenneth J. Mason, 1314 Spruce Street, Wausau, WI 54401; Mr. Kenneth J. Mason 1314 Spruce Street Wausau WI 54401; Dear Mr. Mason: We have received your letter of August 7, 1975, concerning the Unifor Tire Quality Grading Standards established by this agency. Although the formal comment period for the proposals on which this regulation is based ended April 23, 1975, we appreciate your support for the regulation as issued. A copy of your letter has been placed in our public files.; Thank you for expressing your interest. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2145OpenMr. Byron A. Crampton, Manager of Engineering Services, 5530 Wisconsin Avenue, Suite 1220, Washington, D.C. 20015; Mr. Byron A. Crampton Manager of Engineering Services 5530 Wisconsin Avenue Suite 1220 Washington D.C. 20015; Dear Mr. Crampton: In response to your November 24, letter concerning the relationshi between Federal Motor Vehicle Safety Standards No. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C.D. McCarty of the B.F. Goodrich Company on October 15, 1975.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1584OpenMr. Bruce Ladson, Assistant Division Manager, Universal Tire, 14622 Southlawn Lane, Rockville, MD 20850; Mr. Bruce Ladson Assistant Division Manager Universal Tire 14622 Southlawn Lane Rockville MD 20850; Dear Mr. Ladson: This is in response to your letter of August 6, 1974, asking wha registration procedures apply to tires manufactured before May 22, 1971, but sold after that date.; We interpret Part 574 of the Code of Federal Regulations, whic establishes the tire registration requirements, as applying only to tires manufactured after the effective date of the regulation, May 22, 1971. Therefore, tires manufactured before that date need not be registered.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0382OpenMr. Charles J. Calvin, Managing Director, Truck Trailer Manufacturers Association, 1413 K Street, N. W., Washington, DC, 20005; Mr. Charles J. Calvin Managing Director Truck Trailer Manufacturers Association 1413 K Street N. W. Washington DC 20005; Dear Mr. Calvin: This is in response to your letter of June 30, 1971, to Mr. Douglas W Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning your revised drawings showing the location of lamps and reflectors on various truck trailers.; Lamps and reflectors mounted as indicated on your three drawings, TTM 42171, would meet the location requirements of FMVSS No. 108.; Sincerely, E. T. Driver, Director, Motor Vehicle Programs, Office o Operating Systems; |
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ID: aiam0289OpenMr. W.D. Nonnamaker, Director-Tire Engineering and Development, Seiberling Tire & Rubber Company, Akron, OH 44309; Mr. W.D. Nonnamaker Director-Tire Engineering and Development Seiberling Tire & Rubber Company Akron OH 44309; Dear Mr. Nonnamaker: This is in reply to your letter of January 28, 1971, to Mr. Dia concerning Part 574 - Tire Identification and Record Keeping regulations and to confirm that the fourth grouping, date code, may be placed at the end of the tire identification number by means of a separate serial tin and be separated from the third grouping by a space which will not exceed 3/4 of an inch.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.